On October 13, 2017, President Trump outlined a US strategy towards Iran, including his decision not to certify Iranian compliance under provisions as established by the 2015 Iran Nuclear Agreement Review Act. The US Department of the Treasury also announced the designation of Iran’s Islamic Revolutionary Guard Corps (IRGC) pursuant to Executive Order (EO) 13224 (previously sanctioned under EO 13382 in October 2007) and an array of additional sanctions targeting Iran.

On August 2, 2017, the President signed the Countering America’s Adversaries Through Sanctions Act of 2017, which calls for an expansion of a wide range of sanctions targeting Russian, Democratic People’s Republic of Korea (DPRK), and Iranian activities. The new legislation reflects bipartisan support for limiting the flexibility of the administration to lift sanctions without congressional review. While the actual implementation of the Act remains unclear, the increasingly complex sanctions environment reinforces the need for financial institutions and multinational corporations to continually assess their exposure to sanctions-related risks. The following analysis of the legislation highlights key new and expanded provisions for sanctions and provides some examples of their potential impact.

The November 2016 peace accord between the Colombian Government and the Revolutionary Armed Forces of Colombia (FARC) includes a 180-day FARC disarmament deadline on May 29, 2017. By most accounts, the FARC has been slow to comply with the demobilization process, raising questions about the future of the peace agreement, and the sanctions relief that could accompany political normalization with the FARC. Colombian President Santos, who met with President Trump on May 18, 2017 in Washington, DC, has already publicly indicated that the deadline for full FARC disarmament may need to be extended. Although the UK revoked the FARC’s terror-related designation last fall, the group remains sanctioned by the US as both a terrorist and narcotics trafficking group. Recent reports of breakaway FARC commanders and military factions — many with extensive histories in drug trafficking — suggest a continuing threat of FARC-related criminal activity. The FARC has also yet to disclose a significant portion of their illicit assets for use as reparations, as required by the accord.

In October 2016, the United States substantially lifted sanctions on Burma as an economic incentive to continue positive political developments within Burma. The lifting of sanctions is intended to encourage an increase in international commercial activity with, and foreign investment in Burma. Corporates and financial institutions with exposure to Burma should consider the illicit finance and money laundering risks that underpinned the sanctions measures, many of which persist regardless of the political dynamics.

The Houthi group and forces aligned with Yemen’s ex-President Ali Abdullah Saleh have exercised control over several Yemeni financial institutions, including the Central Bank, since seizing Yemen’s capital city of Sanaa in late 2014. During the same period, Al Qaida’s local affiliate “AQAP” also expanded its presence in Yemen, increasing the group’s exploitation of the Yemeni financial system to raise and move funds.